We are Bigblu Broadband Operations Ltd, 60 Gracechurch Street, London, EC3V 0HR (Company Number: 06759661), trading as ‘Brdy’. Where we refer to ‘we’, ‘us’ or ‘our’, this means Brdy and our group companies. For the purposes of GDPR Brdy is the data controller and our registration number is: ZA185544. Brdy and its group companies are committed to protecting and respecting your privacy. 
Please read the following privacy policy, which covers in detail the information we collect from you, how we use it and how we keep your information secure. 

WHAT OUR PRIVACY POLICY COVERS 
This Privacy Policy covers Brdy’s treatment of personally identifiable information that we collect from you. 
This policy does not apply to the practises of companies that Brdy does not own or control, or to people that Brdy does not employ or manage. 
There may be links within the pages of Brdy’s website that will take you to other web sites. Please make sure you read the privacy policy of any other sites that may ask for personally identifiable information before you register with them. 
This website is not intended for children and we do not knowingly collect data relating to children. 

WHAT WE COLLECT AND HOW WE USE IT 
Brdy collects a minimal amount of personally identifiable information to manage your interaction with us as a customer and also any information which you supply us with when completing any of the contact forms on the Brdy website or via any of the other means listed below. 

Brdy also automatically receives and records information on our server logs from your browser including your IP address, browser type and the pages you request. 

We may collect and process the following data about you: 

• Name(s) 
• Email address(es) 
• Phone number(s) 
• Language preference 
• Gender 
• Billing and or Installation address 
• Payment information (Credit/Debit card information, Bank information for Direct Debits/SEPA payments) 
• Company name (if a business customer) 
• VAT Number (if a business customer) 
• Transaction data which includes details about payments to and from you and other details of products and services you have purchased from us 
• Technical data which includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website 
• Profile data which includes your username purchases or orders made by you, your interests, preferences, feedback and survey responses 
• Usage data which includes information about how you use our website, products and services 
• Marketing and Communications data which includes your preferences in receiving marketing from us and our third parties and your communication preferences 
• Your tax details 
We collect this data in the following ways: 
• On the phone when you speak to us 
• Via email 
• Via web forms on our website 
• Via an online chat system on our website 
• Written correspondence 
• Via analytics providers, other third parties or publicly available sources 
Brdy uses this data/information for the following purpose: 
• It enables us to customise the advertising & content of the web site and direct the site’s development in ways that are suited most to your needs and interests 
• To process transactions using state of the art SSL encryption using SagePay (Protx), PayPal and Realex systems 
• to carry out our obligations and to enforce our rights arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us 
• to notify you about changes to our service 
• to ensure that content from our site is presented in the most effective manner for you and for your computer or device; and 
• to comply with any legal obligations we have as an Internet service provider 
• If you are a shareholder we also need to process your personal data to comply with our legal and regulatory obligations as a company whose shares are traded on the AIM market of the London Stock exchange 
• We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: 
• Where we need to perform the contract we are about to enter into or have entered into with you 
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests 
• Where we need to comply with a legal or regulatory obligation 
• Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message 

CHOICE / OPT-IN 
Brdy users are given the opportunity to opt in to having marketing information sent to them at the time of registration. If you have not opted-in, we may still send direct marketing information to you on other legal bases. If you do not wish us to send you direct marketing you may email us or write to us to request that your name be taken off our contact list and all databases (other than suppression lists to ensure that we respect your wishes). You can write to us at Brdy, 10 London Mews, Paddington, W2 1HY or email us here: GDPR@Brdyservice.uk 
We do not send unsolicited marketing emails to personal email addresses (spam). 

COOKIES 
Our websites use cookies to store information on your computer. Some of these cookies are essential to make our site work and others help us to improve by providing insight into how our sites are being used. 

INFORMATION SHARING AND DISCLOSURE 
We may share your personal data with any member of our group of Companies, which means our subsidiaries, as defined in section 1159 of the UK Companies Act 2006. 
We may share your information with selected third parties including: 
• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with you 
• Euro Broadband Infrastructure S.a.r.l for the purpose of allowing them to undertake service quality surveys 
• Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you 
• Professional advisers and our Nominated Adviser and Broker 
• Our share registrar and its service providers 
• Financial intermediaries and lenders 
We may disclose your Customer Data to third parties: 
• In the event that we sell or buy any business or assets, in which case we may disclose Personal Data to the prospective seller or buyer of such business or assets 
• If Brdy or substantially all of its assets are acquired by a third party, in which case Personal Data we hold about our customers will be one of the transferred assets, subject to normal fair processing notices being issued to you 
• If we are under a duty to disclose or share Personal Data in order to comply with any legal obligation, or in order to enforce or apply our standard terms and other agreements; or to protect the rights, property, or safety of Brdy, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction 
• If we need to respond to legal summonses, court orders or other legal processes 

WHERE WE STORE DATA AND YOUR RIGHTS 
The data that we collect from you is primarily stored and managed in the UK, but may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. The transferring and storing of any Personal Data outside of the EEA will be done so with applicable data protection laws. 

All information you provide to us is stored on secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. You should not to share a password with anyone. 

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. 

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal or confidential data to these websites. 

Brdy takes every reasonable precaution to protect users’ information both on-line and off-line. 
We do not link personally identifiable information to administration information received. 
We will not buy other information, which can be linked to your personally identifiable information that we hold. 

YOUR LEGAL RIGHTS 
You have the following rights, which you can exercise free of charge: 
You can ask us to: 
• provide you with a copy of the Personal Data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations provide a copy of your Personal Data (the right of access) 
• correct any mistakes in your Personal Data 
• delete your Personal Data—in certain situations 
• restrict processing of your personal data—in certain circumstances, e.g. if you contest the accuracy of the data 
You can object: 
• at any time to your Personal Data being processed for direct marketing (including profiling); 
• in certain other situations to our continued processing of your Personal Data, e.g. processing carried out for the purpose of our legitimate interests. 
You also have the right to complain to the supervisory authority in the European Union where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.  
Where we are processing your personal data on the basis of your consent, you can withdraw it at any time. 
If you would like to exercise any of those rights, please email us on GDPR@Brdyservice.uk 
Your objection (or withdrawal of consent) may mean we cannot perform the services you have requested of us or you may not be able to use the services we offer. We will advise you where this is the case. In certain circumstances even if you withdraw your consent we may still be able to process your personal information if required or permitted by law or for the purpose of exercising or defending our legal rights or meeting our legal and regulatory obligations. 

CHANGES TO THIS PRIVACY POLICY 
Brdy may amend this policy from time to time to take into account developments in the site and changes to information collected. If we make substantial changes in the way we use your personal information we will notify you by posting a prominent announcement on our web pages or by email. 

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